Privacy Policy

Last updated: February 3, 2025

1. Introduction

At Synucure Therapeutics Inc. (“Synucure”, “we”), we are committed to protecting your privacy, which is why we have implemented a personal information protection program (as defined below) and appointed a Privacy Officer to address any questions, comments, or complaints you may have regarding your privacy.

Synucure is a Canadian biotechnology company conducting research on degenerative brain disorders, with a mission to develop a drug capable of halting and potentially reversing the progression of Parkinson’s disease.

This Privacy Policy (the “Policy”) describes our privacy practices and aims to explain how we collect, use, store, share, and protect your Personal Information when you visit our website, www.synucure.com (the “Site”).

The information on our Site is intended for healthcare professionals and other organizational stakeholders involved in the field, providing them with more information about Synucure’s activities. It is not a communication channel for patients, who will be redirected to a healthcare professional if they contact us.

2. Personal Information

For the purposes of this Policy, “Personal Information” means any information about an identifiable individual, including any information that can directly or indirectly identify that individual.

3. Personal Information Protection Program

To protect Personal Information, we have implemented policies, practices, and procedures for managing the Personal Information we hold. All of these policies and practices have been approved by our Privacy Officer. The collection of your Personal Information by Synucure complies with the requirements of this program.

4. Privacy Officer

The management of the Personal Information Protection Program is the responsibility of our Privacy Officer. Their role involves managing and internally monitoring Synucure’s Personal Information Protection Program.

The Privacy Officer is responsible for approving and implementing Personal Information protection policies and procedures, ensuring their proper functioning, and reporting to Synucure’s senior management on the effectiveness of the program.

The Privacy Officer is also the point of contact for providing necessary assistance in case of questions, complaints, or requests related to Personal Information protection:

Privacy Officer
Synucure Therapeutics Inc.
1002-16 Place du Commerce,
Montreal, Quebec H3E 2A5
info@synucure.com

We are committed to responding promptly to your requests.

Upon receiving a complaint, the Privacy Officer will conduct an investigation. If the complaint is substantiated, the situation will be corrected. Regardless of the outcome, we will keep you informed.

5. Legal Basis for Processing Personal Information

Synucure must collect and process certain Personal Information in order for you to use our Site.

When we collect your Personal Information, we ensure that we only gather the information necessary to achieve one of our disclosed objectives, as previously outlined, for example, in this Policy. We use Personal Information in accordance with applicable privacy laws governing our activities.

Here is a description of the legal basis for the collection and processing of your Personal Information by Synucure:

Your consent
As required by applicable privacy laws, Synucure collects the majority of your Personal Information based on your voluntary consent, primarily collecting it directly from you.

Other permitted legal basis, such as the fulfillment of our contracts
As permitted by applicable privacy laws, Synucure may collect Personal Information without your explicit consent, for example, to comply with legal obligations or to fulfill our contracts.

6. Information We Collect

We may collect the following types of information, depending on the nature of your activities on our Site:

  • Personal Information: Name and email address, for example, when you fill out a contact form available on the Site.
  • Usage Data: Information about how you use our Site, including your IP address, browser type, and operating system.
  • Cookies: A cookie is a small text file that is stored in a dedicated location on your computer, mobile device, tablet, or any other device when you use your browser to visit an online service. These technologies are not necessarily stored on your computer or device. We only use cookies that are necessary for the operation of the Site and provide basic functions. We cannot disable them from our systems without affecting the operation of the Site. However, if you prefer, you can block or delete them by modifying your browser settings and forcing the blocking of all cookies on the Site.

 

Personal Information of Minors

Given the importance of protecting children’s privacy, we do not intend for the Site to be directed at a minor audience. In cases where Synucure may collect Personal Information from minors, we will require explicit consent from the holder of parental authority, the guardian, or the minor aged 14 and older, depending on the applicable case.

If a parent or guardian discovers that their minor child has provided us with Personal Information without the appropriate consent, the parent or guardian has the right, upon request, to review the Personal Information provided and/or request its deletion from our records. In such cases, we ask the parent or guardian to contact us using the contact details provided in the “Privacy Officer” section.

7. How We Use Your Personal Information

We use the information we collect for the following purposes:

  • To provide our services via the Site.
  • To respond to your questions, requests, comments, or complaints.
  • To follow up on your request and communicate with you.
  • To comply with any applicable law or regulation, or to act in accordance with them, including, but not limited to:

    i. to protect our operations and legitimate interests or those of our affiliates;

    ii. to enable us to pursue available remedies or limit the damages we may incur, etc.

  • For any other purpose to which you have consented.

 

If we wish to use your Personal Information for a purpose not mentioned above and for which you have not consented, we will ensure that we request appropriate consent from you or inform you of the change, as permitted by law.

8. Sharing Your Personal Information

We do not sell your Personal Information to third parties.

We share your Personal Information with third parties for (i) achieving our objectives, (ii) responding to legal requirements or requests under applicable laws, (iii) fulfilling tasks entrusted to us by contract with our clients.

In most cases, you have already consented to such sharing. Sometimes, applicable laws also allow us to share your Personal Information with third parties without your consent in specific cases.

More specifically, we may need to share your Personal Information, sometimes without your consent:

With our employees
In the course of their work, our employees and executives may have access to your Personal Information, for example, when you contact us through our Site. Access to Personal Information is limited to what is necessary for the performance of their respective duties.

With our service providers
Our business partners may sometimes need access to or receive certain Personal Information in order to fulfill their services (cloud data hosting, maintenance, analysis, and development). In such cases, we implement reasonable contractual and technical safeguards, including Privacy Impact Assessments, to ensure that these third parties maintain strict confidentiality of all Personal Information they process.

Please note that these third parties may be located outside of your country, province, or territory of residence. For more information on this, please refer to the “Third Parties Located Abroad” section.

With Authorities or Persons Authorized by Law
We may share your Personal Information if required by law or if we believe in good faith that such action is necessary to:

  1. Comply with the law;
  2. Comply with an order from a competent judicial authority in any jurisdiction;
  3. Comply with legal procedures;
  4. Protect and defend the rights or property of Synucure;
  5. Enforce or verify your compliance with any part of the contracts you have entered into with us, if applicable;
  6. Prevent fraud or any other illegal activity conducted through the Site; or
  7. Act in urgent circumstances to protect the personal safety of Site users or the general public.

With Potential Buyers of Our Business
We may need to share your Personal Information without your consent in the event of a merger, acquisition, or sale of all or part of the business, for example, as part of due diligence. In such cases, we limit the sharing to what is necessary to assess the feasibility or opportunity of the transaction.

Third Parties Located Abroad
Your Personal Information may be communicated and stored outside of your province, state, territory, or country of residence.

Our business partners and service providers are sometimes located in Canada or other countries. Please be aware that we have contractual agreements with these third parties and service providers to ensure that your Personal Information is processed in accordance with applicable laws. When applicable, we conduct Privacy Impact Assessments prior to transferring Personal Information to another jurisdiction, such as outside of Quebec.

9. How Long Do We Retain Your Personal Information?

Synucure will retain your Personal Information only for as long as necessary to fulfill the purposes for which it was collected, in accordance with our internal document retention policies, and to comply with applicable legal, tax, or regulatory requirements. After the retention period has expired, any Personal Information held by Synucure will be destroyed, deleted, or anonymized.

10. Security

The security of your Personal Information is a priority for us. That’s why we implement various security measures to maintain the safety of your Personal Information.

Our employees and service providers are informed of the confidential nature of the Personal Information collected and are made aware of the appropriate security measures to prevent unauthorized access to Personal Information.

However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

11. Your Rights Regarding Your Personal Information

Depending on the applicable laws, your place of residence, or how you interact with the Site, certain rights may be granted to you regarding the Personal Information we hold about you.

For example, you may have the right to:

  • Access the Personal Information we hold about you.
  • Request the correction of inaccurate or incomplete Personal Information.
  • Demand the de-indexing of your Personal Information.
  • Obtain additional information, such as the categories of third parties to whom we disclose your Personal Information.
  • Request the portability of your Personal Information in a structured, commonly used, and machine-readable format.
  • Withdraw your consent at any time, if we have collected and processed your Personal Information with your consent. The withdrawal of your consent will not affect the lawfulness of the processing we carried out prior to your withdrawal, nor the processing of your Personal Information based on legitimate grounds other than consent.
  • Refuse promotional communications from Synucure, if applicable.
  • File a complaint with a personal data protection authority, such as a privacy commissioner or an access to information commission.

 

Filing a Complaint

You may file a complaint with Synucure’s Privacy Officer if you are dissatisfied with how we manage your Personal Information or with our compliance with this Policy.

You are also permitted by law to file a complaint with a privacy commissioner or any other competent personal data protection authority.

 

Exercising Your Rights
You can exercise the rights listed above by submitting a written request to our Privacy Officer. The officer will assist you with your request if needed.

We may need to verify your identity before processing your request. According to applicable laws, we will inform you of the procedure to follow, the processing time, and any required information, if necessary. We strive to address requests promptly, typically within 30 days.

As part of the processing activities covered by this Policy, Synucure does not make decisions based solely on automated processing that produces legal effects or similarly significant effects.

 

Changes to This Policy

We may update this Policy from time to time. If we make significant changes, we will notify you by sending a notice on our Site. In other cases, the publication of a new version of the Policy on our Site or your continued use of the Site will be sufficient notice and consent for the changes to the Policy.